Modern Dairy Human Rights Protection Policy
1. Introduction
At Modern Dairy, we are committed to respecting and promoting human rights in our business operations, supply chain and communities. We believe that human rights are the foundation of our vision to create a modern, sustainable, and healthy dairy industry that benefits our customers, employees, shareholders, and society.
2. Scope of Policy
This policy is a public statement of intent that applies to all personnel (including board members, senior management and security personnel) of Modern Dairy and its subsidiaries that have operational control, as well as contract security providers (if any) that provide security services to Modern Dairy and its subsidiaries.
3. Basis for Policy Formulation
Modern Dairy has formulated the Modern Dairy Human Rights Protection Policy by referring to international human rights documents and principles such as the United Nations Universal Declaration of Human Rights, and combining the characteristics and actual situation of Modern Dairy’s business (hereinafter referred to as “this Policy”).
4. Principles
- We respect the dignity and diversity of all people and treat them fairly, equally and without discrimination.
- We respect the rights to life, liberty and security of person as stipulated in the Universal Declaration of Human Rights.
- We do not tolerate any harassment, abuse or violence in our workplace or business relationships.
- We respect the personal freedom and privacy of our employees and protect their personal data.
- We respect the freedom of association and collective bargaining rights of our employees and communicate with them in good faith and constructive dialogue.
5. Human Rights Protection Targets
5.1 Existing Human Rights Protection Targets for 2024
- In our business operations (including the daily work of security personnel), we strive to avoid any serious human rights violations and timely handle and resolve any human rights complaints or grievances.
- In our communities, we actively participate in human rights-related projects and activities and establish good communication and cooperation with local stakeholders.
- In our organization, we regularly conduct human rights protection training for all employees (including security personnel).
5.2 New Human Rights Protection Targets for 2024
| New Human Rights Protection Targets for 2024 | 2024 Target Progress: Achieved |
|---|---|
| 1) Employee Human Rights Incident Management Targets | |
| Forced Labor Incidents: 0 | 0 (Achieved) |
| Child Labor Incidents: 0 | 0 (Achieved) |
| Human Rights-Related Complaint Resolution Rate: 100% | 100% (Achieved) |
| 2) Employee Human Rights Training Targets | |
| Employee Human Rights Training Coverage Rate: 100% | 100% (Achieved) |
| 3) Employee Satisfaction Targets | |
| Business Module Survey Coverage for Human Rights Policy Satisfaction: 100% | 100% (Achieved) |
| Employee Satisfaction with Human Rights Training: ≥ 90% | 99.8% (Achieved) |
| Employee Agreement with Company Human Rights Policy: ≥ 90% | 99.7% (Achieved) |
| Employee familiarity with human rights knowledge: ≥ 90% | 99.7% (Achieved) |
| 4) Community Human Rights Protection Targets: | |
| Resolution Rate for Human Rights Complaints from the Community Related to Company Operations (including receipt, investigation, and resolution of complaints): 100% | 100% (Achieved) |
| Community Violence Incidents Caused by Company Employees: 0 | 0 (Achieved) |
5.3 Human Rights Protection Targets for 2025
| Human Rights Protection Targets for 2025 | 2025 Target Progress |
|---|---|
| 1) Employee Human Rights Incident Management Targets | |
| Forced Labor Incidents: 0 | In Progress |
| Child Labor Incidents: 0 | |
| Human Rights-Related Complaint Resolution Rate: 100% | |
| 2) Employee Human Rights Training Targets | |
| Employee Human Rights Training Coverage Rate: 100% | In Progress |
| 3) Employee Satisfaction Targets | |
| Business Module Survey Coverage for Human Rights Policy Satisfaction: 100% | In Progress |
| Employee Satisfaction with Human Rights Training: ≥ 90% | |
| Employee Agreement with Company Human Rights Policy: ≥ 90% | |
| Employee familiarity with human rights knowledge: ≥ 90% | |
| 4) Community Human Rights Protection Targets: | |
| Resolution Rate for Human Rights Complaints from the Community Related to Company Operations (including receipt, investigation, and resolution of complaints): 100% | In Progress |
| Community Violence Incidents Caused by Company Employees: 0 | |
6. Practice
6.1 Respect for Human Rights
We should comply with applicable international documents and human rights obligations, and respect the human rights and dignity of stakeholders, including our customers, employees, suppliers, contractors, shareholders and the public. We avoid any discrimination, harassment, abuse, or violence based on race, ethnicity, gender, age, religion, disability, or other identity. We strive to provide our employees with a safe, healthy, and inclusive work environment, where they can develop their skills and talents, enjoy their work, and realize their potential. We comply with all applicable laws and regulations regarding working hours, wages, benefits, and social security. We support their well-being by providing health care, education and other social services for our employees and their families.
6.2 Prohibiting Forced Labor
We must prevent any form of forced or compulsory labor, such as all work must be done voluntarily, and all workers must be allowed to freely terminate their employment relationship with reasonable notice. We must not to use any form of threats, violence, restrictions, detention, or other means to force workers to continue working or deprive them of their freedom. We must not restrict workers’ movement or communication in any way, engage in slave labor resulting from human trafficking, or illegally confiscate workers’ identity documents, passports or other important documents.
6.3 Environmental Protection
We are committed to protecting the environment and addressing the challenges of climate change. We adopt sustainable practices in the production, processing, distribution, and consumption of dairy products. We use natural resources efficiently and responsibly, reduce waste and emissions, and promote biodiversity. We respect the right of animals to be treated humanely and cared for.
6.4 Social Participation
We respect the rights of local communities and residents to their land, resources, culture, and traditions. We contribute to the social and economic development of the communities where we operate by creating employment opportunities, supporting local businesses, paying taxes, investing in infrastructure, and participating in charitable causes and philanthropic programs.
6.5 Security Personnel or Contract Security Providers
Modern Dairy requires security personnel or contract security providers (if any) to respect the rights and interests of community residents, carry out security work in a way that respects human rights, comply with relevant laws and regulations and professional standards and codes of conduct, regularly participate in human rights protection training conducted by Modern Dairy, and require them to resolve any possible conflicts in a responsible manner, and oppose the use of violence in any disputes.
7. Expectations
We expect our employees, suppliers, contractors, partners, customers, and other stakeholders to share our commitment to human rights and comply with this Policy. We conduct due diligence on our business relationships to identify, prevent, mitigate, and account for any adverse human rights impacts. We provide channels for reporting any human rights issues or grievances related to our business activities. We investigate any allegations of human rights violations in a timely and transparent manner and take appropriate remedial measures to address any confirmed cases of human rights violations.
8. Training
To better implement this policy, we plan to conduct human rights protection training for employees, and the following are our targets, methods, content, etc.
8.1 Targets: Our training targets are to raise the awareness and understanding of all employees on human rights protection, and to enable them to understand the requirements and principles of this Policy, and how to respect and promote human rights in their daily work.
8.2 Methods: We conduct human rights protection training at least once a year, covering all employees. We adopt online training as the form and push the training notice to all employees through the Office Automation (“OA”) Collaborative System. Our human rights protection training requires all employees to participate. After the online training is completed, the training screen recording will be uploaded to the “Niurenhui” learning platform, so that all employees can view and learn at any time. In addition, we will use newsletters or graphic propaganda to convey the policy requirements, precautions, or violations of human rights protection.
8.3 Content: Our training content includes the following aspects:
- The basic concepts and international documents of human rights protection, including UN Declaration of Human Rights, as well as the background and purpose of this Policy.
- The key contents and principles of this Policy, as well as our specific measures and expectations regarding environmental protection, community engagement, and in particular, guidance for security personnel and contract security providers (if any) on how to interact harmoniously with the community and avoid conflict.
- The implementation and supervision mechanism of this Policy, as well as our reporting channels and remedial measures.
9. Grievance and Reporting
We encourage all employees, suppliers, contractors, partners, customers, and other stakeholders to report any actual or suspected violations of this policy or any applicable laws or regulations. The company provides multiple confidential reporting channels, allowing stakeholders to submit complaints or reports via phone, email, or other means.
- Employees: May submit complaints directly to their immediate supervisor or the head of their respective Human Resources department. The HR department head will acknowledge receipt and document the specifics of the complaint, including date, time, and location, within three business days, and forward all records to the Human Resources Department. Employees may also submit complaints directly to the labor union, the Discipline Inspection Commission Office, and the Compliance Department.
- Suppliers, Contractors, and Partners: May contact the Discipline Inspection Commission Office directly. Contact information for the Discipline Inspection Commission Office is posted on bulletin boards near our farms, at the farm gates, and in the dining hall.
Discipline Inspection Commission Office:
- Email: jijianjubao@modernfarming.cn
- Phone: 18655597719
10. Handling of Human Rights Violation Incidents
Modern Dairy is committed to addressing all allegations of human rights violations promptly and effectively. We will take the following steps:
10.1 Receipt and Documentation: All complaints regarding human rights violations will be taken seriously and documented thoroughly. This documentation will include the complainant’s information, the date, time, and location of the incident, the individuals involved, and a detailed description of the incident.
10.2 Initial Assessment: The relevant Human Resources department or the Discipline Inspection Commission Office will conduct an initial assessment of the complaint to determine its nature and severity.
10.3 Investigation: If the initial assessment indicates a potential human rights violation, a formal investigation will be launched. An impartial investigation team, composed of members from the relevant Human Resources department, the Discipline Inspection Commission Office, and the Compliance Department, will conduct the investigation to ensure transparency and fairness. The investigation team will gather evidence, interview relevant individuals, and prepare an investigation report based on their findings.
10.4 Resolution: Based on the investigation report, the company will take appropriate action, including but not limited to:
- Disciplinary action against the violator(s), such as warnings, demerits, demotions, dismissal, or termination of employment.
- Providing necessary support and assistance to the victim(s), such as counseling, medical aid, or legal aid.
- Revising relevant policies and procedures to prevent similar incidents from occurring.
- Cooperating with relevant government authorities to pursue legal action against the violator(s).
10.5 Follow-up and Audit: The company will follow up on and audit the resolution to ensure its effectiveness and fairness.
11. Monitoring and Audit
We conduct human rights risk assessments on our business operations every year to identify, prevent, mitigate, and account for any adverse human rights impacts. We audit and monitor the implementation of this Policy annually, which includes whether contract security providers (if any) comply with this Policy to inspect and verify policy effectiveness.
- Audit process and methods: We use questionnaires to monitor the compliance of this Policy, and conduct audit coverage of the whole group by randomly issuing online questionnaires, and conduct surveys on the human rights protection situation of employees and contract security providers (if any), and the survey is conducted in a confidential manner. The group conducts audit evaluation and monitoring the effectiveness of its human rights once a year.
- Audit results: The company updates the Human Rights Protection Policy, tools, processes, and targets based on the assessment results of compliance with this Policy to ensure its effectiveness. For key risk issues, any changes in risk level, or new and emerging risks, they will be reported to the management in a timely manner. We welcome feedback from stakeholders on how we can improve our human rights practices. We seek to learn from best practices and collaborate with others to advance human rights in our industry and other fields.
The Company will also conduct regular audits and updates of its human rights policies and procedures to adapt to the evolving human rights landscape.